https://www.taxtmi.com/caselaws?id=403545 Reassessment under the Income-tax Act, 1961 cannot be sustained on reconsideration of the same material. The earlier view that oversight, inadvertence, or mistake in the original assessment could justify reopening was held incorrect to that extent, because a concluded assessment cannot be reopened merely to correct an error noticed on the same facts. "Reason to believe" must rest on tangible material with a live link to escaped income, and a mere change of opinion by the Assessing Officer is impermissible as it amounts to review rather than reassessment. The reference was answered on that basis and the appeal was left to be decided on merits. en-us Wed, 27 Jan 2021 00:00:00 +0530 Wed, 07 Apr 2021 15:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=403545 Reassessment under the Income-tax Act, 1961 cannot be sustained on reconsideration of the same material. The earlier view that oversight, inadvertence, or mistake in the original assessment could justify reopening was held incorrect to that extent, because a concluded assessment cannot be reopened merely to correct an error noticed on the same facts. "Reason to believe" must rest on tangible material with a live link to escaped income, and a mere change of opinion by the Assessing Officer is impermissible as it amounts to review rather than reassessment. The reference was answered on that basis and the appeal was left to be decided on merits. Case-Laws Income Tax Wed, 27 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=403545